Jose Andrade v. Hammond Board of Public Works, 9 F.4th 947

Jose Andrade owned a Hammond, Indiana apartment building that the City inspected and found unsafe, prompting administrative enforcement under Indiana law.
The Hammond Board of Public Works and Safety held an evidentiary hearing; a first Board order was reversed by the Lake Superior Court for lack of notice to Andrade.
On a second inspection and properly noticed hearing, Andrade subpoenaed the City’s Chief of Inspections for materials; the City did not comply, the Board found the building unsafe, and ordered repairs or vacancy of most units.
Andrade sought and exhausted judicial review in Indiana state courts; the Lake Superior Court and Indiana Court of Appeals upheld the Board, and the state and U.S. Supreme Courts denied further review.
After state appeals concluded, Andrade filed a federal complaint under 42 U.S.C. §§ 1983 and 1985 alleging due-process violations arising from pre-judicial conduct (false testimony, failure to comply with subpoena, discriminatory enforcement); the district court dismissed for lack of jurisdiction under Rooker–Feldman.
The Seventh Circuit reversed: Andrade’s federal claims arise from independent pre-judgment injuries caused by administrative actors, so Rooker–Feldman does not bar federal jurisdiction; the case was remanded for further proceedings (preclusion defenses remain open to the district court).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rooker–Feldman bars federal jurisdiction over Andrade’s §1983/§1985 claims arising from administrative enforcement later affirmed by state courts	Andrade: injuries stem from defendants’ pre-judgment conduct before state-court review, so claims are independent and federal court may hear them	Defendants: Andrade is a state-court loser seeking review of matters affirmed by state courts; Rooker–Feldman deprives district court of jurisdiction	Court: Rooker–Feldman does not apply because claimed injuries preceded and are separable from state-court judgments; jurisdiction exists and the case is remanded
Whether Andrade’s federal claims are “inextricably intertwined” with state-court judgments (thereby triggering Rooker–Feldman)	Andrade: his claims challenge administrative actors’ conduct independent of the judicial rulings	Defendants: the federal suit effectively asks the district court to overturn state judgments that affirmed the Board	Court: The correct inquiry follows Exxon — focus on source/timing of injury; here injuries were prior and independent, so they are not inextricably intertwined for Rooker–Feldman purposes

Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (establishes the modern, narrow Rooker–Feldman test)
Rooker v. Fidelity Trust Co., 263 U.S. 413 (original articulation that lower federal courts cannot reverse state-court judgments)
D.C. Court of Appeals v. Feldman, 460 U.S. 462 (applied Rooker principle to certain state-court rulemaking/admission decisions)
Verizon Maryland Inc. v. Public Service Comm’n, 535 U.S. 635 (Rooker–Feldman does not bar review of executive/administrative action)
Sykes v. Cook County Cir. Ct. Prob. Div., 837 F.3d 736 (distinguishes injuries caused by state-court judgments from independent prior injuries)
Swartz v. Heartland Equine Rescue, 940 F.3d 387 (example where injury flowed directly from state-court orders and Rooker–Feldman applied)
Jakupovic v. Curran, 850 F.3d 898 (two-step Rooker–Feldman analysis and opportunity-to-raise-in-state-court inquiry)
Iqbal v. Patel, 780 F.3d 728 (explains district-court jurisdiction over injuries from out-of-court events that state courts failed to remedy)
Jicarilla Apache Nation v. Rio Arriba County, 440 F.3d 1202 (Tenth Circuit: administrative decisions affirmed by state courts may still be subject to federal review)
Thana v. Board of License Comm’rs for Charles County, 827 F.3d 314 (Fourth Circuit: Rooker–Feldman does not bar federal claims challenging state administrative actions)